ML20008F542
| ML20008F542 | |
| Person / Time | |
|---|---|
| Issue date: | 04/02/1981 |
| From: | NRC - INTEROFFICE STEERING GROUP ON DEVELOPMENT OF A SAFETY |
| To: | |
| References | |
| FRN-45FR71023, RULE-PR-50 NUDOCS 8104210167 | |
| Download: ML20008F542 (48) | |
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SECOND PLENARY SESSION 9
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17 PRESENT:
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MR. SEGE:
Cood rorning.
Walccme to the second day 3
of the NRC safety Board workshop.
ue are starting out tr.
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day with a planary session devoted to interin reports fren 5
each of the three panels, for the purpose of letting each 6
panel know what is happening in the other panels, and perhaps 7
generata scme cross-fertili:stion of idaas for the centinuing 8
dis cussicn.
9 After the reports of the panel chairmen, thare vill 10 be opportunity for other participants to offar connents and 11 suggestions and viewpoints, particularly with respect to 12 subject matter that is dealt with in panels other than their 13 ovn, so that the further discussions today could progress in s,
14 directions that sculd be helpful towards a good interfacial 15 consideration of the subject in the plenary session temorrow.
16 sefore turning to the report of the first panel, 17 Walt Kato has a ccuple of announcements to make.
Walt?
18 DR. KATO:
Good norning.
Now that you all knee who 19 you are, would you please turn your namecards arcund so that l
20 the other panel mnmhers can identify you.
Thank you very 21 much.
22 I have got a couple of announcements.
The reccrding 23 firm, the reporters, have indicated that transcripts are 14 available if you wish, however, the charges for the j
15 transcripts will be to you, not to the workshop, so I just i
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. ~ - - ~ - - - -
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wanted to warn you that if you sign up for transcripts, the f~
2 bill will go to you or your conpany, and so I am just so 3
varning you.
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DR. JOKSIMC' TIC:
New serious are the ccnsequences?
5 DR. KATO:
I don't know.
I asked the reporter, but 6
he wasn' t sure either.
There is an amount menticned on the 7
sheet, but he is not sure -- that the is the standard charge 8
that the ACRS transcripts ara given at, and he is not sure 9
what they will charge.
It is very expensive.
10 MR. SEGE:
Thank you, Walt.
I should have mentioned 11 that there is also another iten we have on the agenda this 12 morning between the panel chairmen's raports and the discussion 13 from the floor.
14 In response to our suggestion by Gerry Charnof f, as l
15 well as others, I asked Lester Lave to give a brief highlight 16 report concerning the practices of other agencies with l
17 respect to safety goals, other safety regulatory agencies.
18 This is based -- Lestar's raport is based largely on a study j
19 that he is in the precess of conpleting under contract with 20
- rRC.
21 Mow, I wculd like to ask Dr. Herbert Kouts to give 22 the repcrt of Panel A.
Herb ?
23 DR. KouTS:
Well, we arrived at a fair consensus en 14 a lot of things, some of which are trivial, some of which are 25 not, and sone lack of consensus on other things, so I will try
4 1
to give the flavor of things in all categories.
es 2
We did agree that there cught to be quantitative 3
safety goals in nuclear pc rer.
However, it was realized that rm 4
it may be dif ficult to implement safety goals if thay are 5
constructed in poor ways, and it may be dif ficult at best to 6
implanant safety goals that are quantitativa.
Now, this vill 7
depend on the structure of the gcals.
8 It vill depend en the mechanisn for deternining 9
compliance with goals.
This may particularly at the outset 10 of the establishnent of quantitative safety goals reduce their 11 va lue.
12 This is not a predicticn.
It is by no neans clear 13 that this vill actually be the case, but it is senething to i
14 bear in nind.
It is a res arvation to be kept in mind.
15 We agreed that the quantitative goals shcult. have 16 a qualitative overlay which should be understandable to the 17 public at large, to laynen.
Cne example of a qualitative 18 overlay that was presented was nuclear power should be saf er 19 than any of of the cc,poting ways of producing electric power.
20 This was by no neans a unanimous view of what the l
l 21 qualitative overlay should be.
There were seme reservations 22 on this, and there was in fact a range of views as to what 23 the qualitative overlay should look like, but it was totally i
24 agreed that thera should be a qualitative overlay, that tha 25 goal itself should be a qualitative goal, and tba quantitative
3 1
goal should be a means of implamenting the qualitative gcal, s
2 interpreting it.
3 It was believed that we probably would not be abla
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4 to jump right into implementation of a quantitative safety 5
goal even if it is established, and we should not jump right 6
into it.
There ought to ba a transition period during which 7
safety goals are used as a kind of touchstone to establish 8
the validity of currently oxisting regulatory practices, 9
regulatcry requirements.
10 It may in fact be a very 1cng transition period, 11 and there is some possibility that we never get out cf this 12 transition period, that this is how quantitative safety goals 13 would be used even in the long run, rather than this being the 14 touchstone to deternine whether say an individual plant is 15 licensable or safe or something of the sort, that this 16 establishes the means by which a secondary set of requirements 17 are established for making plants er safe er scmething of the i
18 sort.
19 It was noted that although we do need -- it is 20 sensible to proceed with establishing safety goals, both 21 of a qualitative and quantitative character, that this may 22 nou have very much impact en nuclear gewer plants until, ch, t
i 23 say about the turn of the cantury, considering the pause in l
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24 construction which nov exists, unless these saf ety gcals l
15 provida some basis whereby plants currently being constructed t
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are backfitted with featuras that may be derived as a result s
2 of safety goals having been established, and if this is the 3
case, if the real application of safety gcals, the real m
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impor tance, is to be attached to plants which are, say 20 5
years down the line, we vill have to be quite forward-6 thinking in the way ve construct these goals.
7 The purposes of safety goals were discussed, and 8
ve agreed en two reascns for having safety gcals, just as a 9
logical start, one to protect the public health ard safety, 10 and two, to make the regulatory process -- the verds are more 11 ra tional.
Scre said less irraticnal.
12 It was agreed that it was not a purpose cf safaty 13 goals to make nuclear power more acceptable to the public, 14 although it was also pointed out that if safaty goals are 15 establishe, which do not -- which lead to unacceptability of 16 nuclear power by the public, this vould be a useless 17 enterprise.
18 Understandability of the saf ety is clearly a 19 required characteristic, but certainly not an objective 20 eithar.
21 Goals thenselves could incorporate censarvatism in 22 the quantitative linits which are established, thcugh this i
23 is not necessarily the case.
There is ser.e feeling that as a 24 natter of fact the argunent has to be looked at very 25 carefully to establish whether er net we do vant censarvatism
7 1
in the nuclear field basad on a cost-benefit analysis, m
2 The analytical mathods wheraby compliance with goals 3
is determined should be completely realistic.
That is, in
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calculations, do not introduce conservatisms into the 5
calculational methods to datermine compliance.
If you are 6
going to put in conservative bias, put it in tha linits 7
themselves, where it is clearly seen.
8 We did not arriva at any logical basis for 9
derarminirq the quantitative -- well, the limits to be put 10 into quantitative safety goals.
There were several 11 sugges tions.
Scme vere partisan to cne suggestion, some 12 partisan to another.
13 Some of tha suggestions vera that nuclear power s
14 should provide no greater -- only a given -- no more than a 15 given fraction to total risk of man's activities.
16 Another was that nuclear power, the risk from 17 nuclear pcNer should be less than the risk frcm competing 18 technologies, and here there is also a vie < that ccmpeting 19 technologies may not simply be those that produce 20 electricity, because in the long tern, if we think, say, 23 1
21 years down the line,' these may be technologies that produce 22 s ynthetic fuel, that produce space haat, and so cn.
23 There was some belief that Ib7its should be set as 24 the result not of camparisens anong tec..nologies of any kind,
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25 but en a cost-benefit basis.
That is, if you need the
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1 alectricity, then you should be villing to allow a cartain 2
dysbenefit as a result of it.
3 Finally, there was some view that none of these is n
4 really going to work, and what you cught to do is simply pick 5
some numerical limits that everyone thinks are clearly 6
acceptable to the informed public and perhaps some of the 7
uninfor:,ed public.
8 At this point, we began to get into quantitative 9
saf ety goals and the day ended.
We were -- the day ended as 10 ve began to take up the first aspects o f the ACRS proposal.
11 MR. SEGE:
Thank you, Herb.
Dr. Lester Lave, Panel 12 g,
13 DR. LA*?2 :
Af ter some of the sharp words that were 14 exchanged yestarday morning here, I think that those of you 15 in Panels A and C vould have had tears roll down your cheeks 16 to see formar adversaries getting together, congratulating 17 each other on the positions they had taken on nuclear power, 18 declaring that they individually had been vreng and scmetimes 19 had had impure motives.
20 I am sure that George was -- it was too had that he 21 missed the beginning of our session where ve had a unanimous 22 vote to praise the !TRC staf f for penetrating lucid documents,
23 for a set of venderful questions, unanimously applauding the 24 panel titles, the memberships, and in general the set-up of 25 the meeting.
d 9
1 DR. LEUIS:
This is April 2nd.
s 2
DR. LA"E:
Indeed, ny task as a chairman was made 3
easy by tha lucid discussion, and I have a set of slides to m
4 she< you which reflects the lucidity.
Nov, lat me try.
5 We decidad that "a had our own set of issue: that 6
va vanted to talk about, and so let me just go through those 7
rather briefly.
8 Ws started out with the usual question of why is 9
the public apprehensive, and got a whole set of f eelings of 10 why that is so, about whether the public was ignorant, of 11 whether journalists were stupid, or had ulterior motives and 12 so ca.
13 I think that it was pointed cut that by and large 14 the public is not a set of dumb people who dcn't react -- or 15 who react irrationally to things.
The problem is one of 16 information, and the cost of information, but even if va talk 17 about technically educated members of the public, we don't 18 always get people who are well-informed about the issues of --
19 such as nuclear.
20 cne of the most impcrtant points nade in our 21 meeting had to do with whether the nuclear agency was 22 paranoid, and there it was remarked the only reason was that 23 your agency would regard itself as being singled cut is that 24 it doesn't know enough about what is going on with other 25 in du stries.
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Literally every. igh-tachnology industry around, s
2 and nany that are not high technology are under public 3
scrutiny --
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4 DR. JOKSIMOVIC:
They are all paranoid.
5 DR. LA'rE :
Pardon ne?
6 DR. JOKSIMo'rIC:
They are all paranoid.
7 nR. LAVE:
Nell, remember, paranoia is believing 8
that you hav e enemias and being Nreng about that.
I think 9
that the answer is no, high technology and so cn, thay are 10 not paranoid.
There really ara all sorts of people cut there 11 who don't --
12 "OICE:
You know the saying, even paranoids have 13 enamies.
14 DR. LAVE:
We talked about he< it is that the 15 ragulat.ory process can be enhanced, and that was really much 16 more a matter of trying to get the right questions answerad 17 instead of worrying abcut why some single group was being, cr 18 some group was being singled out.
19 I think that the general comments reflected that 20 the nuclear industry is not being singlad cut, that thara 21 really is lots of mistrust being heaped en tachnology in 22 general, and one of the characterisations was to try and
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23 dif ferentiate between the sort of inheren?. feelings people 24 have abcut technology.
15 There are a set cf technology optimists who regard i
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what has been going on in che last hundred or so ya?rs as 2
being the best thing that ever happened to the human race, 3
and believing that the faster we implement new technology the
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4 better of f we vill all be.
5 opposing them are a set of technological 6
pessimists who don't regard what has been happening as 7
marvelous for the human raca, who see disastrous potential 8
all the time.
9 One way of sort' of phrasing that issue was, is it 10 necessary that all problams with a technology be solved before 11 that technology is implemented, and you get quite different 12 ansvers from the e<o groups en that kind of a question.
13 Tha second area that we vere trying to look at was 14 vhat should t..e regulators have in mind when they are trying 15 to go about looking at safety, and hers we vare trying to 16 sketch out what some of the relevant attributes were, and we 17 have this sort of grocery list at the top, changas in life 18 expectancy or changes in prenature deaths, the difference 19 batveen then raally is the axtent to which one aggregates and 20 hev ene aggregates across individuals and across tira, changes 21 in norbidity rates, changes particularly in disability or 22 chronic illness, a general category of nonefficience or levels 23 of consumption, various kinds of noneconomic or aesthetic 24 values such as species extinction and so on, institutional 25 changes, civil liberties and so on, and the amount of W
12 1
resources that are requirad to be devoted to the ragulatory 7
2 process per se, that is, ens of the things that nobody saens 3
to want to do, which is spand an indefinitely large arount e.
4 of resources en che regulatory process itself.
5 And of course, life gets mora complicated still than 6
tha t, because there is no succinct easy way to tal% abcut, 7
for exanple, 10,000 cases whera life is shortened to scne 8
axtant, and so ono has to look at distributional affects in 9
sone nera detail.
10 For example, which of these effects occur now, which 11 of then occur latar, and hev does cne ma%e the now and later l
12 connensurate sonehov.
Dcmastic and foreign effacts, affects 13 on the rich versus the poor, aff acts en the old versus tha 14 young, effects en the public varsus varicus cccupationa'l 15 groups, er af facts on inditiduals versus groups, af f ects by 16 race, by gender, or by region, where in ganaral, the question 17 is, who gives and who gets.
18 I want to enphasize that while we posed this general l
l 19 sat of questions, we immediately said that any regulatory 20 body that was required to consider all of thase explicitly 21 was never going to make a decision, that this was sinply l
l 22 paralysis, but that this was the ranga of issues that ons had t
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23 to have in mind, and that if any ragulatory body, for example, t
24 focussed only on these first three categcries, of health 25 natters, and naglected the rest, then they were going to I
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arrive at poor decisions, so that this is a sort of a pai-tial 2
list to keep in nind as cna is thinking about decisions, even 3
if one is gcing to do thesa things implicitly.
4 Ne thought that one had to look at some of the 5
advantages and cisadvantages of quantifying safety goals, and 6
I carefully redid the notes so it looks as if thara are more 7
advantages than disadvantagas, even though our discussion 8
sho"cd the reverse.
9 Cno of the major a.ivantages is that it allevs 10 comparisons to be made with other kinds of technologies, with 11 ochar situations in lif e.
12 If cne is able to sketch out sone risk lovels, even 13 if they are not very precise, then you can define other kinds 14 of situations.
By analogy with food and drugs, one of the 15 advantages of quantificatien is that it enables the agency to 16 require detection limits that are lass than what is 17 scientifically possible.
18 Cne of the nistakes that FSA and Congress made in 19 the early i ys was saying that their goal was no detectable 20 amount.
The prcblen is that analytical chemists were far 1
21 smarter than anybody ever dreamed, and it is really a 22 bankrupt practice to try and talk about no detectable amounts,
23 since somebody vill find ways of detecting levels that you 24 never dreamed possible.
15 The third was that quantification permitted tha
14 1
notion of a diminimus risk.
If you didn't have quantification 2
you didn't know what a diminimus risk was.
And then we get 3
into scme more ganeral advantages of quantification.
It 4
permits sort of the reporting of experisnce and of learning, 5
so that one has some idea over time what your track record 6
has been, whether it is good or bad, and what should be done 7
about it, and permit consistent rather than ad hoc decisiens.
8 It may be that in the English common lav, that a 9
marvelous body of doctrine gets built up over tire, and you 10 are talking about a nodern regulatory aqancy handing out a 11 rslatively small number of decisions.
It is not quite clear 12 that they ara going to get any consistant set cf decisions 13 cut of this without scr.e quantitative framaverk.
14 Another notion was one of the educational value 15 of quantificatien both inside che agency and cutside, to tell 16 people rather precisely what you had in mind, without 1*/
reifying the numbers, that it permits one to be fairly precise i
18 about what was intended.
19 A track record fcr evaluation, and then ene of tha i
20 discussicas we had between two lavyers, and I must say I am
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21 vary suspicious whenever two lawyers agree that sonething is 22 marvelous because it will lead to less litigation.
The 23 notion was that by establishing some sort of generic rule that 24 we would probably hava less litigation in the future.
If we 25 ever had two econcmists together that this change was w
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marvelous because it vould maan less employment of econ'cmists, 2
I need hardly say there would be a lot of suspicious ncn-3 economists around.
4 In terms of some disadvantages, the first and 5
principal disadvantage is that there is a decided tendency to 6
ignora matters which can't be quantified.
No matter how oftan 7
one says that the following notions are important, but can ' t 8
be quantified, people start falling in love with numbers, and 9
tending to give short shrif t to those matters which can't be.
10 Sort of an ancillary problem associated with that 11 is that once ona starts ga: ting into reans of numbers, it is 12 very easy to kind of camcuflage value judgments.
Teu simply I
13 stick things in there and r.obody sees them again.
14 One of the probls_ms is that many of us ara geal-15 crientad, and if you set up a nunbar such as getting to scne 16 risk level, then there is a fixation on that numerical goal, 17 people move heaven and earth to get there, and it may turn 18 out that you wanted to have a little bit of a more of a 19 balanced approach to it than simply trying to meet exactly, 20 that.
21 There was an issue about whether the analysis was 22 complete.
There is this danger again in setting numerical 23 goals when you set those numarical goals as to whether they l
24 were anccmpassing all that you wantad to encompass.
25 Another issue down here is that the quantificatien l
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vill have then of f ect of pinpointing certain shortcenings, and 2
probably lead to a sort of a verse trouble in the short run, 3
that i,s, that cnce these things are put down on paper, tha 4
agency's fldvs vill be revi.alad for all the world to see, and 5
it vill be sene tins befora sone respensa can be made to thosa 6
kinds of flaws.
7 one idaa hera was whethar it was pessibla to 8
quantif y qualitative changas, such as var.
That is, vero thara 9
very inpertant aspects that vere being ignored in all this, 10 and then a final notien was that at least if one icoks at the 11 reactor safety study, there is a clear tendency for the l'
goals to be hidden.
I3 That is, that one of the advantages -- or ona of tha 14 attributas one would like o have of the systen that tha goals 15 and the procass be transparent for all to see, all to argue 16 about and appreciate, and the nore conplex one rakes tha 17 calculations, the less transparent these things are going to 18 be.
19 As Panel chairnan, I carefully tried to survay what 20 everybody knev, and then tried to find the topics that nobcdy
'l knew anything about, and it turned out that tha narvelous l
topic knew anything about was epistanology, and so of course
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23 ve spent a long period of tine talking about that.
I 24 The idea vas, what can really be quantified in this 25 araa, and hev certain can we be about the nature of tha
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17 1
quantifica tion.
That is, ara we going through the medieval 2
exercisa of hoe many fairies can dance on the haad of a pin 3
or is thera actually something that can be measurad that we a
4 can have confidence in, and this is one where we didn't 5
resolve things particularly well.
I think we are going to 6
have the jcy this norning of going back and spending the whola 7
morning talking about it again.
8 The idea is that with respect to routine operations, l
9 that we are pretty good with quantification, figuring out 10 what the consequences are out to many decinal places, but 11 when you start getting over to accidents, than there ara a 12 nunbar of dif ficulties.
13 sone of the criticisms of NAsu-1430, if you 14 renember, had to do with whather the events were actually 15 independant, whether conbinations of events had been 16 considered, and then whether there were important 17 unrecogni:ed events, as inevitably there are.
18 And vc had some ideas about whether you could 19 actually calculate what everybody would accept as upper l
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20 bounds, which was 1&< enough so that it would be meaningful 21 in some sense.
22 As I say, those issues vere not resolved very well.
23 And then, soma of the matters that wa intend to taka 24 We want to spend some time on implenentation of up.
25 quantitative goals.
The first notion here is one of trying to L
13 1
look at narrow technical gcals versus goals that are 2
understandable to the public, hev you manage to make the two 3
comnansurata sonehov.
Thst is also part of the notion of hev 4
it is that you get some vonderful global set of goals that we 5
all agree with, and then translating then down to verkable 6
goals, naking sura that what is learned then at the level of 7
working with these goals gats translated up again into high 8
level goals, that is, naking sure that thare is censistancy 9
anong the various levels.
10 And then, ve want to spend sone time talking about 11 hov it is that you get the systen to cperate as designad if 12
<e nanage to settle en all these goals, and how it is that 13 the goal process itself rill be af fectad by tha e:: tant to 14 which you believe you can get the various systa s to operate 15 as designed.
16 And then the final area that we vant to get into is 17 talking about the process for what I will call identifying 18 and involving stakeholders, that is, who does have sranding 19 here, and ho< nuch standing do they have to protest or have 20 their views known about various parts of the process?
21 The principal notion here is ona of trying to find 22 felicitous processes, that is, processes that manage to 23 involve the right people in the right way, so that you manage 24 to get issues resolved, get comprenises nade rather than 25 having people go into highly dysfunctional behavior, and the
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notion here is one of trying to look at cenparative e
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2 advantagas anong various groups.
3 Well, those are notions that we havan' t gotten into u
4 yet.
I think I have probably talked too long, and I will 5
stop.
i 6
MR. SEGE:
Thank you, Lester.
Dr. Paul Slovic, 7
Panel C.
8 DR. SLO"IC:
Well, I think we 'did raach one point 9
of consensus regarding the ACRS document, and that is we 10 agraed, I think, with their statement that nanagement of 11 risks is as nuch a sociopolitical problem as a technical one.
12 Af ter that, the going got a little bit rougher.
13 We spent quite a bit of time at the beginning 14 trying to get our bearings on issues such as the distinction 15 between goals and rules, and there was some feeling that we 16 should focus on goals at this time, and that rules were --
l 17 quantitative rule developnent was a bit premature.
18 However, the subsequent discussion ueened to con-19 found the two again, reflecting what I think is a continuing 20 uncertainty as to how goals would be cperationalized or 21 implemented.
22 We spent also sans time discussing the development 23 and the philosophy behind the ACRS guidelines in ordar to 24 familiarize.ourselves with that a bit nora so that we could 25 proceed then to discuss the sociopolitical issues relevant to
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the ACRS proposal.
2 I think basically our discussion did contar on the 3
general question, which is what are the nain economic, ethical 4
and scciopolitical issues in the formulation of nuclear power
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5 safety goals, and secondarily we did address the questice how 6
does the ACRs proposal deal with these issuas.
7 We are still fornulating the answers to these 8
questions, but scce preliminary version of it is as follows:
9 Ameng the naicr ccncerns that were identifiad were 10 the following:
11 rirs t, there was concern that quantitativa goals 12 night captura er deninate t' e decision process, driving out 13 valuable qualitative stand:rds er procedures.
For exanple, 14 there was concern that the great uncertainties in 15 quantifying certain facters and the problems of varifying that 16 these quantitative criteria vare met might lead to sort of >
17 number ganes and hand-waving and designed to giva the 18 illusion of satisfying these criteria at the expense of 19 emphasis on some sound tried and true principles such as 20 def anse in depth.
21 The counter to this concern was the view that l
22 quantitative goals vould really be only part of the precass.
23 They would be designed to supplanant thase other procadures 24 rather than to replaca ther.
25 Wa talked a bit about tha probic= of public 1
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accaptance of thase goals.
I think we probably shculd verk 2
cn this scne nore, but there was sone -- at laast three 3
dif ferent views en the inpact and relavanca of quantitative 4
geals to public seceptancs.
5 sene f elt that rational coharent goals would 6
enhance the public trust, rhich is so inpcrtant to the 7
nuclear enterprise.
8 There were others who felt that actually the 9
quantitativa goals night raduce confidence and trust.
Fcr 10 example, there was a feeling that the public would have 11 difficulty understanding these goals, and would actually 12 have more confidence in principles such as defense in depth, 13 which sort of hava a nere detarninistic and raassuring 14 elenant to then, that the public senehee had a bettar feel 15 for those kind of princip12s, rather than the cenplex 16 quantitative goals that they dcn't understand and don't 17 believe can be verified.
18 Finally, there was a view that in a certain sense 19 these goals could proceed independent of specific concarns 20 abcut public acceptance, that is, that the public should be 21 censulted where issues of values were relevant for 22 incorpcraticn into those goals, for exanple, attitude tev3rds 23 catastrophic loss of life, cr the inportance of that is an 24 issue where societal values shou ld cone into play, but that 15 basically these goals vers to be used as guides for dacision-
22 1
making on the part of bodias such as the ACRS, and that they 2
could precaed -- they would be valuable in that light alona, 3
regardless of the impact on public acceptance.
4 5: ell, I think there was a lot of -- as you can sea, 5
there are different pcsitiens, and there is no agreemant on 6
that point.
7 Secondly, we considerad the problem of scale, which 8
saaned not to be reflected in the ACRS document, and that is, 9
does it nake a differenca thether you ara designing goals for 10 a systan with 50 reactors er 100 reactors, or perhaps a 11 thousand reac, tors?
There cas a feeling that it did na%a a 12 differance.
For exanple, thera was concern that thera r.ight 13 be seno slippaga in the design, licansing, monitorinc cr 14 anergency raspense capabilities as a function of large scala, 15 and that these problems needed to be addressed.
16 There was also a feeling that scale vould -- this 17 is a related problem -- that scala Nould af fect tha i
18 availability of trained personnel, that anothar related issus 19 is the sort of mix cr dependence en mix of power supply 20 systams, the dependance en nuclear power, that if the i
21 dependance got too great, doesn't this produce a cartain 22 vulnerability to problens chat arise, so that if there vara
~
13 industry shutdowns, we wou..i be in a quita dif ficult 24 positicn, and what is the relavance of this for quantitative 25 criteria?
W.
13 1
Another related issue that has to do with scala 2
is that with the large scale, large number of plants, you 3
have the mora likely possibility of individual serious 4
accidents which could have -- which carry with them major 5
societal and industry costs, just the sheer frequency of 6
these accidents would increase, and sanehov this shculd be 7
f actored into quantitative goals.
8 We also spant some time discussing ethical issues, 9
also these two are not dir.setly addressed in the ACRS 10 proposal.
There was a general feeling that it is desirable 11 to conpensate those on when risks are imposed.
Fcr exampla, 12 if cne noves to siting in a relatively unpopulated araa, 13 in order to lover the expected loss of life, given an 14 accident, then somehow these people shculd be compensated for 15 the imposition of this risk upon them.
16 We separated these ecmpensation or equity issues 17 into t<o catagories, those dealing with the spatial 18 distribution of risks and benefits in the current genaration, 19 and those dealing with the intartemporal or intergenerational 20 problems, passing risks along to the future, and there was 21 general agreement that while there are some principles for 22 dealing with these intergenerational equity issues, they are 23 much more complicated even than the -- you kncv, there was 24 at least some hope of dealing erith the equity issues in the 25 currant generation, the spatial equity problens, but the
24 1
intartemporal problems would be very dif ficult to really 2
incorporate into any criteria at the present time, not to say 3
that they should be ignored, but that there are immensely 4
complicatad issues having to do with hev do you -- you know, i
5 how does the future value certain ris's that ycu vill impose 6
upon them in order to give them certain bsnefits, he< do ycu 7
make those decisions?
8 There were discussions of principles such as trying 9
to leave the future with a menu of oppertunities t."at is vary 10 much the same as the -- as exists for tha current generation 11 and so fcrth.
12 There was a discussion of disecunt rates, that is, 13 can you or should you have a disecunt rate en ecsts er lives 14 lost that are imposed on future generations.
Some felt that 15 a :ero discount rate was really the mest justifiable, meaning 16 that you just sinply count lives lost in the future the same i
17 as lives lost in the present.
I 1
l 18 There were others who felt that ene could discern i
l l
19 situatiens where you wouldn't want to have a zero discount l
20 rate, or where you act as though there not such a rata, ycu 21 kncv, where you would act to save lives now more forcafull y 22 than to save them in the future, but that even then there was i
13 no specific or censtant rate that raally could be applied, l
l 24 so I think the general consensus was that this is an impcrtant i l
25 relevan t, but immensely dif ficult problem to deal with.
s
1 Just in passing, there was a connent that the ACR5 2
proposal seens to neglect genetic risks.
It seen: to assune 3
that latant cancers are an appropriate surrogate for this.
4 This was brought up, questicnad, but ve did not discuss it in 5
any detail.
6 There vas also brief nention given to the problen 7
of hei you daal vith cid er existing plants versus nev plants,
8 vis-a-vis quantitative criteria, and there was concern that 9
thera shculd be a distinction here and that the critaria that 10 apply for new plants should not necessarily apply for the 11 existing plants.
The conec n was that if thera ras a sert cf 12 acrcss-the-board applicability here, then that night laad tc 13 a tendancy to "eaken the criteria for new plants, in crdar 14 net to inposa severe costs en existing plants.
15 Ne did not yet discuss the level of safety.
I 16 think that is an inpertant issue which ve vill get into this 17 nerning.
I 18 Thank you.
19
'R. Smz:
Th an s you, paul.
? cv I veuld like to g I
20 call en tr. Lave to prssent the highlights of his findings 21 ccaccrning the practice of cther agencias.
22 7?.. T7Z :
Father than try to go agency by agency, l
l 23 I an going tn show you a sat cf decisien frareverks nest cf
~
l l
24 which are currently in use and to be prepcsed, and tell you t
i 15 what the agencies are that use these.
In general, there ara j
l I
i l
l r
26 1
relatively few pure cases of any one of thes a frameworks 'ceing 2
used.
3 First, a franevork that is used for the vast 4
maj ority, that is all but a f ev health and saf aty decisions,
5 is narket regulation or individual decision, sone conbination 6
of latting the narket do what it wants, trying to nake sur e 7
that inf ernation is available, for example, about saccharine, 8
and then letting the courts handle cases of vrongdoing of ona 9
sert or ancther.
10 The sacend frame.ork is no-risk, c tha nalaney 11 clause used by the FDA for fcod additivas usad b
-- cr i
12 inposed en EPA by Ccngress, fcr the primary air quality 13 standards.
2asically the idea is that no level of risk is 14 deonad to be accaptable, and at least within this narrev 15 class, the agency is to attampt to get risks dcwn to zero.
16 That franevork proved to be one that FDA did not 17 like, and FDA originally testifiad against the Delaney clausa 18 and has found it uncenfortable to live with it.
In particular
(
19 in looking at sodium nitrita, a suspected carcinogan, tha FDA 20 proposed that it be allowed to censider the haalth banefits to j
21 consumars of having sodium nitrita around, versus the healt?
22 risks of having it around.
They callad this franevork risk-23 risk analysis, and it was the opinion of the attorney ganaral 24 that the language of the Delaney clause was clear, and that 25 they did not have that optien, that they were dealing with l
t l
r
27 1
no risk.
2 Congress has instructed E?A to use technology,
3 based standards in varicus cases.
For example, in tha water 4
araa, Congress tells E?A that the standards shall be best 5
available centrol technology, or one or ancther of thosa.
6 S.ose wind up being a set cf engineering judg.ents.
Uhen they 7
are implanantad in practice, they don't mean what the plain 8
language says.
They don't mean best available technology.
9 What they nean is impose a tachnology which is stringent up 10 until the point where the angineers either have resarvations 11 about whether it vill work in practice, or the industry can 12 no longer af ford it, and without dunping en other disciplines, 13
- nust say that engineers naking judgnents about the 14 profitability of conpanies doesn't let me go to sleep very 15 easily at night.
16 Tha fif th franeverk is risk benefit analysis, and I 17 vill be careful what I say about that in this group.
It is 18 used, at least the name is used by a number of agencies, 19 p:A with respect to drugs, E?A in the TOSCA regulations, 20 Toxic substances Centrol Act, although I scnetines get put en 21 the progran at meetings as an expert en risk-benefit analysis, 22 I don't kncv vhat it is, and it nust be that : just didn' t 23 talk with ancugh practitioners.
24 The sixth franrecrk is cest-effectiveness analysis, 25 developed out of the Departnent of 7efansa, whera you
q I
23 1
reme.aber T:isanhower's Socratary of Def anse, Wilson, said that 2
his objective was to get the most bang for the buck.
The 3
idea is to try and maximiza some goal givan a budget
\\ '
4 cons traint.
Cost-effectivaness analysis night also, for 5
example, come under the >tuclaar Regulatcry Ccmmission's 6
ALARA criteria, where one puts some dollar value on a saving 7
of a man-rem, and then makas sure that all eff orts which 8
could save a man-rom for less than that cost are dena.
9 cne way of implementing the cost-effectiveness 10 framework is the regulatory budget, a proposal that came 11 out of Charlie Schultz' Council of Econcmic Adviscrs.
The 12 idea was to have an implementation budget where tha amount of 13 cost that aach agency could impose en tha private economy, 14 those than would -- that wculd be a separate line item 15 debatad by Congress and set by Ccngress.
16 The final framework is conventicnal benefit-cost 17 analysis, which requires doing all these things that pacple 18 get intense reservations about.
That is, not only finding cut 19 vhat the health ef f ects would be in quantitative terms, but 20 Erznclating then over into dollars, and than adding up the 21 benefits versus the costs.
22 I want to point co all of you chat there is a 23 governmant agency which always has used explicit benefit-cost
~
24 analysis with a full explicit value en lif e, namely the. AA,
25 and in every FAA safety prcycsal they go through and thay
~
29
~
1 quantify lives l'est, preparty damagi cests.
Thay than na%e 2
everything cs.aensurate in dollar terns, and ny questien of 3
these people was, you don' t really nean to say you have a 4
dollar value on pre-ature lif e, and their answer is yes, they 5
do.
They get asked about it every year at appropriatiens time 6
by Congress, but so f ar, that is what they do.
7 The.cre general notion that I vant to bring out 8
here is that you people in the nuclear business ara really 9
luckier than alnest anybody else in the government regulatica 10 of health and safety, because more is kacvn abcut the health 11 ef fects of ionizing radiation than about virtually any 12 toxic substance arcund.
13 If you think for a second abcut whan an FDA 14 Cc=nissicner should be doing when he receives a telegran that 15 says we had 36 salnenella that reverted when ve pcured this 16 substance en then, and we have ten censumer groups that want 17 us to ban the substance inr.ediately, ycu see that the kinds
[
l 18 problems that are faced by other agencies are nuch much more 19 dif ficult than anything having to do with icnising radiation, I
20 and the thing that is interesting about then is that in fits 21 and starts and with nere or less controvarsy, the agencies 22 have fcund ways of trying to live with tha kinds of problams 23 they have, and many of those techniques are of graat 24 interast, I think, for nucisar, for trying to find what 25 cenprenises seen to werk.
l I
30 1
MR. JOKSIMC'fIC :
I don 't see CMSA anphers.
2 DR. LA* 7E :
CHSA Selieves that its statute is a 3
no-risk statute.
CHSA up until this year helieved its 4
statuta was a no-risk statua.
The Suprema Court said they 5
vere wrong.
6 DR. J0KSIMoIC:
don' t kncv that that is true.
7 na. LA'rE; Well, if you go and read thsir statuts, 8
you could naka the argument either way.
Sene of ?.y 09SA 9
friends tall ne the Suprent. Court ade its dacision up out 10 of whole cloth.
The peopla en the other sido said that no, 11 the egency had always been treng, that they had alvays had a
12 dunb ganaral counsel.
I h:ve talkad with bcth the crities 13 and the ganeral ecunsel, and I don't think either of those 14 is true.
It is just that it is a very ambiguous statute.
15 MR. SEGE:
Thank you, Lestar.
16 We are now ready f or cc== ants by participants en 17 the repcrts that you have received, and conments for 18 consideration by the panels in their further discussions.
19 I thought that va night start first with connents 20 that focused primarily en ?anel A, and proceed to Panel 3, 21 and than to Panel C and thnn comments that dcn't particularly 22 relata to a particular panel, but cut across tha dif f arsat 23 tcpics, to the extant that we can.
24 Uhen you make your comments, would you please 25 speak loud and clear, and identify yourselves to tha rapertar
31 I
who can't saa all of the nanotags, ahd~ this identifi~ cation is 2
particularly important if jou ara sitting behind sc~ebody' 3
elsa 's naretag.
4 Any co cents with respect to Panel A?
22. :'a ls ch ?
5
- .ta. :mI.scH :
I had one comment, and it was because 6
of a statement that was made that I think I disagree with, 7
and that is that ycu ought to set the gcals very censervative-8 ly but then accept realistic inplementation measuras, and what 9
I am concerned about is that if we establish very 10 conservative goals, and than provide for realistic 11 implenentation casures, that vould provoka intansa 12 controversy and concern as to whether the goals are met, as 13 opposed to establishing realistic goals, let us say, lessar 14 stringent goals, but then provide for very stringant 15 implementatica.easures, and tharaby dininish centroversy 16 over whether the goals are in fact established, just a 17 comment that I had.
18
>!R. SEGE:
Thank you.
Any other cccments?
T.
19 7 nn 7 20
.va. TE:OtE :
Sty connent is essentially the same, 21 but I would like to add one more thing to it, I think.
I 33 think the objective of naking the calculations realistic is 23 probably not acheivable, because each of us has his own
~
24 definiticn of realisn, and that leads to a lot of 25 centroversy, as was pointed out.
I don't think it is a i
m 32 1
necessary objectire, either.
I think the real need is to 2
specify what the calculations are when the goal is stated, and 3
ve can have that argument, but I think -- don' t think we cught 4
to get caught up in the arqunent of whether er not the 5
numbers are realistic.
That is notivated, it seens to ne, by cne of eso 7
r eas cn s.
The first is that as engineers, when we are trying 8
to neet goals, we like to :hink that we are perf orming cast-9 ef f ective tradeof fs, cptimisation, if you vill, and !! va are 10 using cenplex analytical ncdels in which are embedded in a 11 very uneven annar censarvatisns, we can be completely 12 nisicd by cur calculations.
13 And se it is desirable fren that psrspsetivs to 14 hava realistic calculat:icna of accident sequence probabilitics 15 and so fcrth.
16 he other notivation seens to be that if -- cna 17 that appeals less to =e -- and that is that if we put a let 18 cf ccnservatisms into our risk estinates and they cene cut 19 locking high and then we are accused of trying to kill a let 20 of pecple or senething of that nature, and we becere 21 defensive about that, the Other side of tha coin is that we 22 can also do calculatiens which produce infinitesinally small 23 numbers, and then we are told who are ycu trying to kid, and
~'
24 I don't think we should be overly influenced by those kinds 25 of reacticns in what we do.
I think -- as I hava said befera
33 1
I thinh thers is an inchntive te do real calculations, to try 2
to do a balanced job cf dasigning an operating plant, but I 3
think the real objective should be to just specify tha 4
calculations rather than to specify that they be raalistic 5
or sonething else.
6 MR. SEGE:
Thank you, Mark.
Any other connants 7
with respect to Panel A?
- 'r. !rutt?
8 MR. HUTT:
As I haard the panel report, they hava 9
reached tha conclusion, I think it was twice stated, that 10 nuclear energy should be safer than competing energy sources.
11 Did I nishaar that?
12 DR. BEYEA:
That is not a conclusion.
That is cna 13 point of view that was expr as sed.
14 MR. HUTT:
I would simply point out that I think 15 the vast majority on our panel concluded quite the opposite, 16 but then I don't know that there is any -- not that it should 17 be nore risky, but that it should be -- there should be a 18 unif orm safety standard for competing enargy scurces.
19 DR. KouTS:
That vould be an altarnative that could 20 be talked about, too.
21
.sm. SEGE:
Thank you, Peter.
Yes,!!r. Burstein?
22 MR. BURSTEIN:
I think that in Panel A, wa tried to 23 deal with the purpose of a safety goal, which as Dr. Kouts 24 expressed earlier in a sunnary, had two f acets, one to protact 25 public health and safety, and the second to make the
34 1
regulatory process acre racional.
2 If the inpositicn of a saf ety goal is acccmplished, 3
it is going to require some means of perhaps denenstrating 4
achoivement or compliance that utilises probabilistic risk 5
assessment er some cther kind of approach.
6 If that is superimpcsed upon c
. ant demons'.:stions 7
of safety cenpliance, as I have heard in some other groups, 8
and as we discussed in cur own panel, as an additicnal 9
regulatory precedural requirement er intent, then I for one 10 vant no part of it, and I uhink we are wasting all cf our 11 zine, particularly f or senothirg, as we said, which may not ha 12 applicable to a genaration of nuclear plants until some 13 significant time 8.1 tha future.
t 14 Unless the development and implamentatien of tha 15 s.afety goal serves to substitute for some of the c rrent 16 regulatory activity, that does not serve to make t. 3 l
17 regulatcry process more rational, but en the centrary, it i
18 makes it more conplicated, difficult, costly, and cenfusing.
I I
19 I think that is a very significant and important issue.
20 MR. SEGE:
Thank you, saul.
21 If there are no further ccmnents on Panel A, we 22 could -- yes, there is one further ccament, Mr. "erby?
23
.'G.
OEREY:
I would like to set forth an opposite 24 view to what was just expressed.
In Panel B what we discussed 25 cr part of the discussica cantered en intuitive decisiens that
,-d $'
1 vore made' en an ad hec basis in the inp'a t-?i:^iicn' cf current 2
!!uclear P.egulatcry Cc :nissien standards.
3 In the sensa that a quantitativa geal veuld 4
formlize that intuitive ad hec decision process, it would 5
suppla ent the presant standards.
I fcr ene think that is an 6
advantage, and akas that sof t process of ragulaticn a littla 7
nera regulated, tc use the verd, but aise : ake explicit 8
declarations of what goes i.tc that scf t part.
That seens to 9
be where the issues arise.
That seems to be where the delays 10 are seen, so I vculd like to of fer that oppcsita point of 11 view to the fact that replacing what is th re is tha only 12 goal, cr the cnly purpose of a quantitativs standard.
In 13 fact, I think there is a supple ental advantage f or additicnal 14 for alizaticn.
15
- 23. SE02:
Thank you, Steve.
"r. O'Ocnnell.
16
- G. o ' xtr': ELL :
I would like to of f er a viewpoint 17 cn this also.
I think, speaking for niself as an industry 18 representative, the problen with the current regulatory 19 scructure, is not sc uch that the current requirenents are 20 burdensene.
- can, they are being net.
The prcblen is cna 21 of pradictability and change, which is at present 22 uncontrolled in any sys.anntic nanner, and I sculd viev ch6 23 application of quantitativa safety goals as senething ec 24 control that cha. ige, and I think that we are not lecking to 25 replace existing requirenents, including cencects such as
36 1
def anse in depth, and throwing then cut and introducing 2
secething cenpletely new, but the quanticative safety gcals 3
vculd be a means of naastring what is the level cf safaty that J
4 is prcvided by this existing set of regulaticns, and if it 5
does in fact give a lavel of safety that is <ithin these 6
top leval goals, ve should then be focussing en ths need to 7
change those requirements en sene quantitativa basis, and 8
specifically the use of tha cost-benefit aspect of the gcals, 9
to make these changes, those decisions en faith, and I think 10 that is the most constructive use of the quantitative safety 11 goals, not to throw out what va have, but to introduce 12 predictability and systematic decision-naking into tha need 13 for changa.
14
!G. SEGE:
Thank you.
Mr. Levine.
15
!3. LE't:ME :
- guass this is a very inpertant 16 atter that is being discussed nov, and we discussad it 17 extansively yestarday.
I sense that thera is sene confusien 18 about this natter.
People saen to be regarding the fact as, 19 ve either have existing require ents or ve have quantitative 20 safety goals, er we have bcth, and : think none cf those is 21 right.
22 I think the idea of having quantitative saf ety 13 goals is -- well, one has to talk about he< one vill use than.
I 24 I don't think they should be used in the licensing precess, 15 but they should be used in the ragulatory precess.
That is,
_ _ ~
37 1
they should nct bef used in thd licensing proca's5 to desermine 2
whether a particular reactor meets them or doesn't meet tham, 3
but they shculd be used in the background to look at the 4
rationality of existing so-called deterministic requirements, s
5 to r.ake than nore rational, and those are the requirements 6
that should still be used in the licensing process, at least 7
f or tha foreseeable futura.
8 Ihis came up in Panel C, in fact, if I can say a 9
werd about Panel C, where in talking about the public 10 acceptance of goals, the statamant was.ade that the idea of 11 defense in depth would have mere appeal to the public than a 12 set of numbers, again, I d n't think it is either/cr.
13 No one is going to throw out the idea of defense in depth.
14 No one is going to threv cut all the safety engineering 15 design requirements that new er.ist, which can't be co 2 red by 1
16 PRA or quantitative goals.
17 so it is not a question of either/cr.
It is a
(
1 18 question of supplanenting cur existing NRC requirements with 19 another tool to hs'.p them make it nore rational, but not to 20 throw anything out, er to add anything in particular.
21 MR. SEGE:
Thank you, Saul.
Let us move en new to 22 Panel B.
Any comments en the -- in connection with the Panel U
13 3 report?
Mr. Levine?
24 MR. LE'tI':E : I just have a general question on 15 Panel 3.
I took some notes which make it look like all they
f 33 l
1 did was discuss quantitative goals, and I vandar if they ara 2
going to consider whether cr act we should hava qualitative 3
goals, or what they should look lika, er anything like that.
4 MR. SEGE:
Uculd Dr. Lave please respond to that 5
question?
6 OR. LAtrE :
Cartainly we are.
I guass that we had 7
thought of that -- yes, ve are.
8 MR. SEGE:
That tas a good unequivocal ansvar, thank 9
you.
professor MacLean?
10 DR. MAcLEA:I:
I had three very particular comments,
. 11 Nell, there are t to particular, on e more general, just things 12 tha t I happen to disagrac rith.
13 cne was, it was antioned as cenparing the 14 quantitative, che qualitative values er gcals er whatavar, it 15 was listad as a disadvantage of quantitative goals that 16 attempting to quantif y qualinative goals, that it has a 17 tendency, perhaps to lead to doubt.
I think that is trus, 18 I don't knock it, but I think it is an cpen question whether 19 the problen is nerely to ease things cut c: whether there are 20 some things that in principle cannot be quantified, and I 21 don' t knew if I an disagreeing with you there, but I -- okay.
22 Seccndly, it is listed as an advantage of 13 quantitative goals that they can yield consistent 24 decisiens.
I fcund this pu:: ling because a qualitative 15 decisien principle vill also yield consistent dacisions. The
r-39 T
neasura of consisten'cy it's'alf is dithe'r quantitativa or 2
qualitative, so I think that claining that as an advantage for 3
quantitative gcals is questien-bagging.
4 And third, nora generally, I think, and af tar,having 5
thcught about this myself fcr sono time, and trying to write 6
scne things up on this, I rhink that talk about public 7
apprehensivenes s in terns of tachnological optinists and 8
technological pessinists is more confusing than it is 9
helpful.
10 I an thinking about it, first of all, I don't kncv 11 a single nenhor of Friends of the Earth iho doesn't cvn a 12 5etter stereo than I own.
I have never heard a greatar 13 tcchnological cptinist than Barry Cennenar talking abcut 14 sclar pcwcr.
I have never heard a greatar technolog;. cal 15 passinist than ny colleagues in the nuclear engineering 16 department talking about solar pcNer, and in general I think 17 it is a red herring.
18 MR. SE05:
Thank you, Dcug.
Any othar cc nants en 19 Panal B?
Professer I. avis?
20 SR. ' DTIS :
Just ene, since ve are : aking fun of 21 technologists, I would like to register a gansral but vary, 22 very niner cc.nent, in ene of Lester's slidas.
Ther2 is a l
23 tandancy to always put the verd "narrev" in front cf tha i
24 icrd " technical," and I veuld li':s to register an objcetien to 25 that tendency.
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I 41 1
MR. SEG2:
Thank you, Ed.
Dr. Eischhud?
2 DR. EISEN3U3:
I would hope that at the 3
conclusion of this wcrkshop we don't give the implication 4
that the subject of the risk goals, er safety goals has been 5
introduced de novo and is a concept that is going to arise 6
out of the recent work of che ACRS and the NRC staff and this 7
verkshop.
8 I detected that implication in some of tha 9
discussicns that tcok placa yesterday.
I believa that there 10 is a double chain of quantitation now, and seme risk goals, 11 cr safety goals that have been introduced and gradually 12 inproved er expanded as the technology changes, and I hope 13 that this, I think at some point I think this workshop has 14 to address the really two chains of quantitation leading up 15 to the safety goals.
16 One is based on the fact that there exist certain 17 risk coef ficients that describe the amcunt of haalth danage 18 per unit of radiation exposure, and that information, which 19 comes frca various sources, national and international, has 20 then been incorporated in Parts 20, 5 0 and 10 0 of tha N2C 's 21 Code of Federal Regulations, into what anounts to saf aty 22 goals.
'~'
23 They describe what the goals should be fer nornal 24 operation in Part 20; in Parts 50 and Parts 100, they describe 15 what vould be acceptable in the event of an accident, and ny s
42 1
point of view as a sene c.a distant obsarver is that what 2
Parts 50 and 100 do, Part 100 nore specifically, is deal with 3
the questien, and here con.2s the seccnd chain of 1
4 quantitation, of what the probabilities are of reaching the i '
5 limits given in Parts 20 and 5 0, and there is an implicit 6
acceptance of what the probabilities should be, the 7
probabilities have been described in NAsit-1400, as nodifiad 8
by the Levis Paport and others, but I think all of this 9
constitutas a bcdy of infernation which at the presant tine 10 providas the safety goals en which the NRC policy and 11 ragulatory proceduras ara basad.
12 And I for one ha re not detected yet what the 13 relatienship is of this verkshop to the a.xisting body cf 14 Laformation and body cf practice.
I was trying to -- shculd 15 ve test the present criteria to see whether they are adequata?
16 Have ve decided that they ara not adequata and theraf ere hava 17 to be made nere strict?
18 In s hort, I don't think that we shculd energa fren 19 this verkshop vithout scne continuity fren tha present bcdy 20 cf practice as it now exiscs to whatever ve racc=nend in our 21 report.
1 22 MR. SEGE:
Thank: for the cornant. I an sura that 23 the ranarks that you have ade vill be takaa into account in 24 tha panel discussiens today.
- 'r. Maisch?
25
- G. MALsca:
Yeah, I just vanted to naka a cennent
3 1
in response to that, that there is sort of an implicit goal 2
in terns of normal releases in Part 20 and Appendix (i) to 3
Part 50, because that is based upon the old FRC radiation
'\\
4 detection standards which wera based upon a generalized kind 5
of risk-benefit analysis, and then the overlay on top of that 6
that at least it should be kept as far bel &< those as 7
reasonably acheivable, which is based explicitly en a cost-8 effectiveness analysis.
9 Eut in tarms of accidents there is no probability 10 goal at all established in t o CFR Part 100.
The language in 11 the regulation ref ers to the word " credibility."
That has 12 been debated back and forth for years.
Earlier decisions lead 13 cne to believe that credibility meant conceivability.
La tar i
\\..
14 decisions imply that some sort of probability is involved.
15 But you will search in vain f or any of ficial NRC 16 pronouncement as to what is the quantitative dividing line 17 between a credible accident sequence and an incredible ena.
18 And thus, the particular fccus of the workshop en accidants, 19 which is where there'is'less with respect to probability 20 goals in the NRC's regulatiens as comparad to almost any othar 21 area.
22 MR. SEGE:
Thank ycu, Martin.
Me are running V
23 somewhat behind schedule, so I would like to ask that any 24 further cenments en Panel E should be made only if the commentor 25 considars it to be of considerable urgency to make it this
i 14 1
norning rather than reserve it for possible censideration 2
tenorrow in the longer discussicn.
3 The criterien should be if tha ec= ment would be 4
likely to influence the further deliberations of ?anel 3, 5
it should be nade now.
- 'r. Levine?
6 7
LE'rI:iE :
I hate to do this, but you just said 7
the words that mada ne f eel I had to connant.
In leo %ing at 8
the list of disadvantages to quantificatien, that it ignores 9
what can't be quantified, the valus judgments, et catara,
.10 at catara, et catera.
Thic is trua of any nodal that anycna 11 naxas,.3hether it is quanticarive, qualitativa or what.
'Te 12 cli do it in cur daily lives.
- Te all are nedaina%ars and va 13 all ignera facters that we think can be ignored.
- That va ara 14 1ccking for is ccnsensus around a thing that can ver%, and 15 that vill always hava cenpremisas cf one kind of another.
16 And I find nest cf this list of disadvantages vary i
17 distastaful, and maybe they can usc that connant in thcir 18 further deliberations.
19 Ma. Src :
Nell, thank ycu.
Pref asser Perre<.
20 nn, ?nanoti:
In that spirit, I have a helpful I
21 cv-1ent, too, for the panel.
I an nonplussed by their 22 ccnclusion -- I hope they axploro it in much mora detail, i
13 because we haven't been abla to in our panel, Panol C, the l
l l
24 ccnclusion that quantifyinc these goals is fina if there is 25 no problan, that it is routine operation, but ihan ycu have l
,. -z I
accidan*.s quantifying the goals that dsal with accidents is 2
not raally possible.
I recognise the cenbinations and 3
dependanca and se fcrth, and I sculd say that that is what tha 4
thing is all about, and if act, I an very surprised, sc I 5
hcpe they dovete the whole day to that.
6 DR. SLO":C:
I an s crry, w e didn ' t say it wasn ' t 7
pcssible. We sa d - th ara vere lets of dif ficulties, that i
8 it was relatively single, straightfervard, to leck at reutine 9
cperaticas, and that when you got accidents, the probic. get 10 L nensely nere cenplicated, and I was trying ec spell cut 11 scna of the raasens why it was.
12 Ue have not cene to closure yat in trying to define I3 vhat is hncvable here.
Psrhaps we can spend scna ti.,3 en it.
14 02 PERRC":
Okay, the prolininary list is good.
15 The three things you have 'isted are useful.
16 33, 3333
-hank yeu, Chuck, and Lester.
17 Let us turn nov :c Panel C.
Any ev_... ants en Panel II C?
Paul, ycu are not getting any cennents at all.
Yas, ycu 19 are.
Mr. Tenne?
'O
- 2 TEM"E:
There was the suggestion at ena pcint
'l that the public should be censulted abcut their values, and
,s perhaps it isn't a fair questien, but ny question is, hee do 1
ve consult them?
What do ycu do to censult the public abcut 4
their values?
5
,.s
- 2. SEGE:
Or. 51cvic, vculd ycu cara to respcnd to
46 1
that?
You can either lock at ongoing 3
behavior and try to infer important ccncerns and attitudes from e
4 that, or you can consult with various groups representative 5
of dif ferent public intarests, try to ge t scna fjelings f or 6
it and than decide -- but, for exanple, in tha ACRS 7
docunents, thera are questions,.there are scne philcscphical 8
value decisions anbedded in thosa criteria, which I think 9
are representativa cf attitudes, for exanple, the risk 10 avarsien coefficients.
11 aut I den't think there is any perf act way of 12 cening up viuh the public values, in fact there is no sucP 13 thing in a sanse, but we have to, you knov, it sculd be 14 implicit in whatever standards are set, I balieve.
15 MR. 5 GE:
Thank ycu, Paul.
Professer okrent?
16 DR. OKRE:IT:
I vculd like to nake a request that 17 each of the panels, including the one I an en, try to cone up 18 with either a position er positions er points of viev en 19 shculd there be risk aversien senehow included in what the 20
- RC does, whether it be quantitative er qualitative, and if
' l so, how, and should there he some kind of an ALARA used in 33 design with rsgard to accidants?
And if so, could they 13 suggest how?
'4 MR. SEGF:
Thank you, Save.
Are thero an; cther 15 cennants, either on Panel C, or cennents that shculd be takan
47 1
up at this tir.e, that nay cut across tarious panels?
I den't S
saa any hands, so guess we are ready for adjournecnt cf 3
the planary sessicn.
The panal discussicns rill be starting 4
in approxi.ataly 20 ninute s at tan minutes to ten.
5 (Theraupen, at 9: 3 9 a.m., the planary sassion 6
adj ournad. )
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